Liebeck v. McDonald's Restaurants

Lore & Background

On February 27, 1992, Stella Liebeck, aged 79, purchased a 49-cent cup of coffee from a McDonald's drive-through in Albuquerque, New Mexico. While adding cream and sugar in a parked car without cup holders, she placed the cup between her knees and pulled the lid toward her, spilling the entire contents onto her lap. She suffered third-degree burns on six percent of her skin and lesser burns over sixteen percent, requiring eight days of hospitalization for skin grafting and two years of medical treatment. She lost nearly twenty percent of her body weight and was partially disabled for two years.

Liebeck sought to settle with McDonald's for $20,000 to cover her medical expenses and her daughter's lost income, but McDonald's offered only $800. After the company refused to raise its offer, attorney Reed Morgan filed suit in the U.S. District Court for the District of New Mexico, alleging gross negligence. At trial, Liebeck's attorneys argued that McDonald's coffee, held at 180–190 °F, was defectively manufactured and more likely to cause serious injury than coffee served elsewhere. They presented evidence that McDonald's had received over 700 reports of coffee burns from 1982 to 1992 and had settled claims for more than $500,000.

The jury found McDonald's 80% responsible and Liebeck 20% at fault. They awarded $200,000 in compensatory damages, reduced to $160,000, and $2.7 million in punitive damages. The judge reduced punitive damages to $480,000, for a total of $640,000. Both parties appealed, but settled out of court for a confidential amount before an appeal was decided.

Reader's Guide

The Liebeck case became a flashpoint in the United States debate over tort reform. It was cited by some as an example of frivolous litigation; ABC News called it 'the poster child of excessive lawsuits.' Legal scholar Jonathan Turley argued that the claim was 'a meaningful and worthy lawsuit.' Ex-attorney Susan Saladoff saw the media portrayal as purposeful misrepresentation due to political and corporate influence. In June 2011, HBO premiered the documentary Hot Coffee, which discussed how the case centered debates on tort reform.

Proponents of tort reform often framed the case as frivolous, while detractors noted that McDonald's refusal to offer more than $800 for $10,500 in medical bills indicated the suit was meritless. McDonald's asserted the outcome was a fluke, attributed to poor communications by an unfamiliar insurer. Liebeck's attorney and the Association of Trial Lawyers of America claimed McDonald's reduced its coffee temperature after the suit, though McDonald's in fact had not done so. Liebeck died on August 5, 2004, aged 91; according to her daughter, the burns and court proceedings had taken their toll, and the settlement paid for a live-in nurse.

Did You Know?

• Stella Liebeck was 79 years old when she spilled the coffee and suffered third-degree burns on six percent of her skin.
• McDonald's had received more than 700 reports of coffee burns from 1982 to 1992 and settled claims for over $500,000 before the Liebeck case.
• The jury awarded $2.7 million in punitive damages, which the judge reduced to $480,000, for a total of $640,000.